First Circuit - Firearms

United States v. Stinson, 978 F.3d 824 (1st Cir. 2020). 4-level enhancements at §2K2.1(b)(6)(B) for possession of a firearm in connection with another offense and at §2K2.1(b)(5) for trafficking firearms both applied to a case in which the weapons were stolen during the course of a burglary. Application Note 14 to §2K2.1 “addresses the very facts of this case.”

United States v. Reyes-Torres, 979 F.3d 1 (1st Cir. 2020). The 4-level enhancement at §2K2.1(b)(6)(B) for possession of a weapon in connection with another offense applied because the “totality of the evidence confirm[ed] that the machine gun and ammunition had the potential to facilitate the offense of drug distribution.

United States Tirado-Nieves, 982 F.3d 1 (1st Cir. 2020). The 4-level enhancement at §2K2.1(b)(6)(B) for possession of firearms in connection with another felony offense applied in a case where the defendant possessed drug paraphernalia in a “quantity that was indicative of drug trafficking.”

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